- 4 - In response to respondent’s July 7, 2004, 30-day letter, petitioners sent a letter, dated July 24, 2004, along with their check in the amount of $1,153.23 to respondent. In that letter, petitioners explained that the $8,448 claimed contribution carryover deduction was an error attributable to Turbotax software. In a September 7, 2004, letter, respondent answered petitioners’ July 24 letter, and among other matters, advised petitioners that the changes to their 2001 tax return resulted in a total tax obligation (apparently including interest to August 6, 2004) of $2,528.77. Respondent, on November 5, 2004, sent petitioners a statutory notice of deficiency for their 2001 year determining an income tax deficiency in the amount of $2,327.40. Petitioners thereafter commenced this proceeding. OPINION The controverted item in this case is an $8,448 contribution carryover deduction. Petitioners do not contend that they were entitled to that deduction. Instead, they make a collateral attack, contending, alternatively, that respondent’s deficiency notice was invalid, or that respondent agreed to a lesser deficiency, or that the tax preparation software manufacturer is liable. Petitioners’ first argument is that the 2001 notice of deficiency is invalid. Petitioners argue that the notice has errors and does not reflect the correct amount of income taxPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011